LifeLock 2015 Annual Report Download - page 182

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 24 of 289
49. All personal pronouns used in this Settlement Agreement, whether used in masculine, feminine, or neuter gender,
shall include all other genders and the singular shall include the plural and vice versa except where expressly provided to the contrary.
50. All references herein to sections, paragraphs, and exhibits refer to sections, paragraphs, and exhibits of and to this
Settlement Agreement, unless otherwise expressly stated in the reference.
51. The headings and captions contained in this Settlement Agreement are included only as a matter of convenience and
in no way define, limit, extend, or describe the scope of this Settlement Agreement or the intent of any provision herein.
IV. 
52. As a material part of this Settlement, at the time of seeking preliminary approval, Plaintiffs shall seek leave to file a
Second Amended Complaint (“SAC”) naming Renier Jerome Ebarle as a Plaintiff. The proposed SAC is attached hereto as 
.
53. As a material part of this Settlement, LifeLock stipulates to and does not oppose the filing of the SAC provided that a
Preliminary Approval Order, a Final Approval Order, and Final Judgment each is entered and this Settlement Agreement becomes
effective on the Final Settlement Date.
54. If a Preliminary Approval Order is not entered or a Final Approval Order and Final Judgment is not entered, this
Settlement Agreement and the Settlement proposed herein does not become effective for any reason, or if this Settlement Agreement
and the Settlement proposed herein is terminated, canceled, or fails to become effective for any reason whatsoever, and subject to
paragraphs 112 and 114, the Plaintiffs shall withdraw the SAC within five (5) days of the denial of Preliminary Approval, the denial
of Final Approval, the termination or
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